https://www.taxtmi.com/caselaws?id=782439 ITAT Delhi held that the reassessment initiated beyond four years was invalid as the assessment had originally been completed under section 153B(1)(b), and the AO failed to demonstrate any failure by the Assessee to fully and truly disclose material facts. The AO's "reason to believe" was based solely on information from the Investigation Wing regarding alleged accommodation entries, without independent verification or analysis, amounting to borrowed satisfaction. Since the AO did not establish how the Assessee's disclosures were deficient, the conditions of the first proviso to section 147 were not met. Consequently, the reopening and reassessment order under section 148 were quashed and the Assessee's appeal was allowed. en-us Wed, 26 Nov 2025 00:00:00 +0530 Fri, 06 Mar 2026 11:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=782439 ITAT Delhi held that the reassessment initiated beyond four years was invalid as the assessment had originally been completed under section 153B(1)(b), and the AO failed to demonstrate any failure by the Assessee to fully and truly disclose material facts. The AO's "reason to believe" was based solely on information from the Investigation Wing regarding alleged accommodation entries, without independent verification or analysis, amounting to borrowed satisfaction. Since the AO did not establish how the Assessee's disclosures were deficient, the conditions of the first proviso to section 147 were not met. Consequently, the reopening and reassessment order under section 148 were quashed and the Assessee's appeal was allowed. Case-Laws Income Tax Wed, 26 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=782439